Title VI: Community College of Allegheny County (PA) OCR No. 03-07-2043

On November 8, 2012, by letter, OCR closed a complaint against the Community College of Allegheny County (the “College”) that was filed because of initiatives it had that sought to recruit African American applicants to the College by offering financial assistance with tuition and other school-related needs, and by providing mentoring and support programs once admitted. Eventually, the initiatives were expanded to include skill development and assistance with job placement in specific career fields, largely in the health care industry, that were believed to be in high demand in Pennsylvania. According to the College, these initiatives were targeted towards African Americans, but were not race-exclusive. That is, the College told OCR that students of other races were eligible to participate in both initiatives. OCR stated in its resolution letter that it is not a violation of Title VI, in and of itself, for a postsecondary institution to operate a race-themed mentoring and support program. Such programs are unlikely to be subject to strict scrutiny review if they do not admit or exclude students on the basis of their race and conduct broad-based recruiting, which may include race-targeted recruiting. However, OCR’s investigation revealed the College had abolished the challenged program shortly after the complaint was filed and the College had informed OCR that it did not intend to resume the program. Based on these findings, and consistent with OCR’s case processing procedures, OCR administratively closed this complaint as moot.